## Facts

- A federal district court entered a school-desegregation decree for Duval County, Florida, implementing pairing and clustering of formerly segregated schools.
- Following implementation, unrest and violence occurred at Ribault Senior High School, including a temporary school closure.
- The school superintendent and county sheriff sought injunctive relief against certain non-student “outsiders” alleged to be causing or encouraging disruptions at or near the school.
- The district court issued an ex parte injunction barring identified outsiders, including Eric Hall, from entering Ribault’s campus and from coming about the premises to interfere with school operations.
- Hall was not a party to the underlying desegregation litigation and had no formal legal relationship to any party, but he was personally served with the injunction.
- Hall later appeared at Ribault in violation of the order.
- The district court found Hall guilty of criminal contempt and sentenced him to 60 days’ imprisonment.

## Issues

1. Whether a federal district court may punish for criminal contempt a person who is neither a party nor in privity with a party when that person violates an injunction issued to protect and effectuate the court’s desegregation judgment.
2. Whether Federal Rule of Civil Procedure 65(d) limits the binding effect of an injunction so that such a nonparty cannot be enjoined or punished for contempt.

## Decision

- The Fifth Circuit affirmed Hall’s criminal contempt conviction and 60-day sentence.
- The court held that the district court had authority to issue and enforce an injunction against a nonparty whose conduct threatened to frustrate the court’s desegregation decree.
- The court concluded that Rule 65(d) did not bar enforcement under these circumstances, particularly where the nonparty had actual notice and deliberately violated the order.

## Legal Principles

- Federal courts possess inherent authority to take steps necessary to protect their jurisdiction and to prevent their judgments from being rendered ineffective.
- An injunction issued to protect and effectuate a court’s existing judgment may reach nonparties whose conduct would obstruct implementation of that judgment, so long as they have actual notice.
- Rule 65(d) should be read in light of equitable practice and does not require a reading so strict that courts are unable to issue effective orders preventing third-party interference with court-supervised remedies.
- A nonparty who has actual notice of a valid court order may be punished for criminal contempt for a knowing violation, even absent formal party status in the underlying case.

## Conclusion

The court upheld criminal contempt sanctions against a nonparty who, after receiving actual notice, violated an injunction aimed at preventing third-party disruption of a court-supervised school-desegregation remedy, holding that inherent judicial authority and Rule 65(d) permitted enforcement to protect the efficacy of the judgment.


United States v. Hall, 472 F.2d 261 (5th Cir. 1972)